3 RISK FACTORS, INTERNAL CONTROL AND INSURANCE - Internal control
RUBIS’ CONTROL BODIES Rubis’ Consolidation and Accounting Department runs numerous checks to ensure that financial information is reliable, particularly during accounts closing reviews. The Group’s Management and Finance Department regularly analyze the financial
statements of subsidiaries, and periodically meet with the Senior Managers of Rubis Énergie and Rubis Terminal in order to conduct a review, assess risks and instigate any corrective action needed to achieve the Group’s targets. Lastly, Rubis’ Corporate Secretary, who is in charge of the Legal
Department and to whom the Group’s Compliance & CSR Officer reports, maintains ongoing dialog with the subsidiaries on various topics, including litigation, trademarks, insurance, identification and mapping of risks, compliance (anti- corruption, embargoes, etc.).
3.2.3 INTERNAL RISK MANAGEMENT
MANAGEMENT OF SUBSIDIARIES AND RUBIS Internal risk management, in the same way as accounting and financial internal control, is subject to monitoring by the operational management of the subsidiaries, which keep Rubis regularly informed. At Rubis Énergie, Technical Departments (QHSE) at headquarters establish information repor ting procedures and preventive measures for anticipating and managing risks as detailed in chapter 4, section 4.2.1. Some of the information collected, mainly in respect to health and safety issues, is cross-checked with consolidated data by the Management Control, Audit and The internal control system relies on several channels for reporting information on the main risks, designed to identify sensitive points comprehensively. RISK MAPPING Rubis has developed and set up a mapping of the risks identified as significant, to which the Group’s various activities may be exposed. The analysis of such significant risks also considers their occurrence as well as their financial and reputational impact (on a scale from 1 to 5). The mapping was conducted in close cooperation with Rubis’ Legal, Consolidation, and Finance Departments, All key risks, risk monitoring procedures and the corresponding hedging policies are described in detail in this chapter, section 3.1, and in chapter 4. In terms of risk, the Group operates in business sectors that are tightly controlled and regulated. Its structure is designed to reflect this. All French sites covered by the Seveso directive have safety management systems, whose main purpose is to define the organization, staff functions, procedures and
Consolidation Department, which handles reporting on social responsibility (see chapter 4, section 4.5). At Rubis Terminal, the Technical Departments establish procedures and inspections comparable with those applied at Rubis Énergie. They work closely with local QHSE engineers. The Rubis Énergie and Rubis Terminal Te c hn i c a l De pa r tme n t s r e po r t t h e information on the main risks to their r e s p e c t i v e Ge n e r a l Ma n a g eme n t . Certain events may also be addressed in Management Committee meetings. Lastly, Rubis Énergie and Rubis Terminal lay out the main risks to the relevant departments together with the Rubis Énergie and Rubis Terminal Financial and Technical operational Managers and Depar tment s. A self- assessment is carried out at regular intervals to identify new risks. Significant risks have been divided into various families: market, accounting misc alculation, insurance, busines s, environmental, industrial, climate, supply chain, social, legal, and IT risks. The category relating to legal risks also includes issues related to fraud, contractual breaches, ethics and, until 2017, corruption. In 2018, the Group carried out specific mapping to assess the risks of corruption to which entities may be resources that allow the Group to establish and implement a prevention policy for major accidents. Furthermore, Group entities at both Rubis Terminal and Rubis Énergie operate within the framework of ISO 9001 and ISO 14001 certification, particularly with regard to the establishment and application of safety and environmental procedures and processes (see chapter 4, section 18.104.22.168). Therefore,
they follow processes that are largely formalized. Internal control procedures for risk management and monitoring cover all of the Group’s businesses and assets. These are based on a process to identify and analyze the main risks, underpinned by the appropriate organization which allows Senior Managers to tackle these risks and maintain them at an acceptable level.
22.214.171.124 GENERAL ORGANIZATION OF THE GROUP
of Rubis (Management, Accounting and Consolidation Depar tment, Finance Department and Corporate Secretary, in charge of the Legal Department) through different transmission channels such as risk mapping (see section 126.96.36.199 below).
ACCOUNTS AND RISK MONITORING COMMITTEE
The Ac count s and Ri s k Moni tor ing Committee reviews the organization of internal control and risk management procedures, under the conditions described in this chapter, section 188.8.131.52 and in chapter 5, section 184.108.40.206.
220.127.116.11 IDENTIFICATION AND MONITORING OF THE MAIN RISKS
exposed, in accordance with the Sapin II law (see chapter 4, section 18.104.22.168). Risk mapping is carried out yearly in each division by the operational Managers at each industrial site and by the Directors of the French and international subsidiaries concerned, assisted by the functional Managers of Rubis Terminal and/or Rubis Énergie. They are updated during the year whenever the Management Committee meets. They aim to provide, on a yearly basis, a clear picture of the significant risks that have been identified and any measures that have been taken or need to be taken to mitigate or eliminate them.